Held that when Assessing Officer had rejected assessee’s explanation that investment to tune of Rs. 1.60 lakhs in aforesaid properties was sourced out of cash loan that was raised by him from his relative and had held same as having been sourced out of his undisclosed income, then Additional Commissioner could not have taken a contrary view and saddled assessee with penalty under section 271D for having carried out aforesaid loan transaction, existence of which in itself had been rejected by Assessing Officer. Penalty order is quashed.  (AY. 2012-13)